When Karl Rove’s Crossroads Grassroots Policy Strategies (GPS) formed in 2010, it established its official address in Warrenton, VA, and registered with the Internal Revenue Service a tax-exempt 501(c)(4) “social welfare organization.” It apparently did not, however, register as a charitable organization with the Commonwealth of Virginia, as appears was legally required.

According to state code, non-profit groups that intend to solicit contributions must first register with the Virginia Department of Agriculture and Consumer Services Office of Charitable and Regulatory Programs. Groups must pay an annual fee ($325 for groups raising over $1 million annually), provide basic information about their operations, and must sign statements affirming that no funds “have been or will knowingly be used, directly or indirectly, to benefit or provide support, in cash or in kind, to terrorists, terrorist organizations, terrorist activities, or the family members of any terrorist.”

The Virginia law explicitly exempts political campaign committees that are “required by state or federal law to file a report or statement of contributions and expenditures.” Crossroads GPS has consistently kept its contributors secret as it has raised and spent tens of millions of dollars against Democratic candidates.

While the group’s federal tax filings and registration with the District of Columbia indicate that it is a Virginia corporation — and Crossroads GPS did apparently register with the state’s corporation commission — the Office of Charitable and Regulatory Programs confirmed to ThinkProgress that no entity named Crossroads GPS or Crossroads Grassroots Policy Strategies has ever registered to solicit contributions in Virginia. Additionally, no entity with the tax identification number listed on Crossroads GPS’s tax filings has ever registered with the agency.

A spokesman for Crossroads GPS did not respond to a ThinkProgress request for comment."